Securities compliance in China spans issuers and listed companies, controlling shareholders and actual controllers, directors and senior management, securities and professional-service firms, investors, traders and technology providers. The first task is to identify the security, market, account, disclosure or transaction, every responsible person, and the exact exchange or CSRC request and deadline.
Preserve announcements, board materials, disclosure drafts, insider lists, trade and communications data, account-control evidence, algorithms and change logs, diligence files and every regulatory document. Do not trade, coach witnesses, delete messages, alter records or coordinate accounts after a concern arises. This guide provides national enforcement orientation, not a merits assessment.
Subject to editorial and legal review. Obtain matter-specific advice immediately where trading restrictions, compulsory production, a formal investigation, hearing notice, limitation period or criminal referral is involved.
Map the rule set, actor and procedural stage
Identify whether the matter concerns issuance, continuous disclosure, acquisition, intermediary diligence, insider trading, manipulation, short-swing trading, program trading, account control, suitability or another regulated activity. Record the relevant exchange rules, CSRC measures and professional standards. Separate an exchange inquiry or self-regulatory measure, supervisory measure, formal administrative investigation, penalty proceeding, civil claim and criminal case.
Disclosure governance
The revised Listed Company Information Disclosure Measures have applied since July 1, 2025. Disclosure must be truthful, accurate, complete, timely and fair. Maintain escalation from subsidiaries and business units, materiality assessment, board and management review, draft control, announcement timing and correction procedures. Controlling shareholders, actual controllers and transaction counterparties may hold information needed by the listed company and should have documented notification channels.
Inside information and trading controls
Identify when information became material and non-public, who learned it and why, when access ended, and all related trades or recommendations. Maintain insider lists, restricted lists, wall-crossing records and event chronologies. Account names do not settle beneficial ownership or control; preserve funding, device, order, IP, communication and profit-flow evidence. Avoid after-the-fact reconstruction unsupported by contemporaneous records.
Market manipulation and coordinated activity
Manipulation analysis may examine control or use of accounts, concentrated trading, matched or self-trading, false or frequent orders, price or volume influence, information activity and economic purpose. Firms should monitor abnormal patterns and document legitimate strategies and controls. Communications and algorithms must be assessed together with order-level data rather than in isolation.
Program and high-frequency trading
CSRC's trial program-trading rules have applied since October 8, 2024. Program traders must report prescribed account, funding, trading and software information before trading. Exchanges conduct real-time and abnormal-trading monitoring; securities firms have customer-management duties; institutional users require dedicated compliance and risk controls. High-frequency activity attracts additional reporting, system and monitoring requirements, including under northbound trading arrangements.
Issuers, intermediaries and gatekeepers
Sponsors, securities firms, accountants, lawyers, asset appraisers and other service institutions must act diligently within their professional role and preserve an evidence-based work file. Define scope, red flags, escalation, independent verification and reliance on experts. Management representations or client-supplied documents do not automatically resolve contradictory evidence. Keep this compliance analysis distinct from the separate issuance/listings guide.
Inquiry and investigation response
Issue a lawful hold, identify custodians and systems, preserve original and translated materials, establish one verified chronology and track each request. CSRC powers may include requiring documents, questioning, inspecting, freezing or restricting assets or transactions and other statutory measures. The administrative-penalty rules address evidence, hearings, service, obstruction, illicit-gain treatment and criminal transfer. Cooperate accurately without guessing or destroying context.
Penalty, civil and criminal interfaces
Potential outcomes include exchange discipline, supervisory measures, confiscation, fines, market-entry bans, issuer or licence consequences, investor civil claims, representative litigation and criminal referral. Responsibility is actor- and duty-specific. Preserve causation, reliance and loss issues separately for civil claims, and do not assume that an administrative outcome resolves every private or criminal question.
Working-file checklist
- Security, venue, accounts, entities and responsible-person map.
- Event and disclosure chronology with drafts and approvals.
- Insider, restricted and wall-crossing records.
- Orders, trades, funding, devices, algorithms and communications.
- Intermediary scope, diligence, red flags and escalation.
- Exchange and CSRC requests, productions and deadlines.
- Legal hold, privilege and translation protocol.
- Administrative, civil and criminal exposure map.
Official sources
- Securities Law
- 2025 Listed Company Information Disclosure Measures
- Program Trading Management Provisions
- Securities and Futures Administrative Penalty Measures
Law checked: September 11, 2026. Official Chinese texts and current exchange rules control. Confirm the actor, market, conduct, procedural stage and response deadline before acting.
